UK names cryptocurrency exchanges including HTX in new sanctions package targeting Russia

Today, the UK announced one of the most expansive cryptocurrency-focused sanctions packages to date. The UK has applied Regulation 17A of the Russia (Sanctions) (EU Withdrawal) Regulations 2019 to cryptocurrency exchanges for the first time, significantly expanding compliance obligations for UK virtual asset service providers (VASPs) and reshaping how digital asset companies approach sanctions.

The designation targets various cryptocurrency exchanges, banks, individuals and businesses linked to Russia’s sanctions evasion architecture, including the A7 network. Perhaps most significant is HTX’s designation as one of the world’s largest cryptocurrency exchanges, with 2025 trading volume reaching $3.3 trillion.

Importance of Regulation 17A

Regulation 17A is one of the most powerful tools in the UK’s financial sanctions regime. Historically deployed against designated banks, such as those targeted following Russia’s invasion of Ukraine, the program imposes broad restrictions on correspondent banking relationships and payment processing. Today is the first time it has been applied to a cryptocurrency exchange.

The impact on UK VASPs and institutions is immediate and severe.

Correspondent relationships are prohibited. UK credit and financial institutions are prohibited from establishing or continuing correspondent banking relationships with any UK or non-UK entity owned or controlled by a named person or such institution. For UK VASPs, this means that their relationship with the designated exchange for liquidity, settlement or other purposes must be terminated.

Payment processing across chains is prohibited. UK businesses are prohibited under Regulation 17A from processing payments, regardless of currency, if the funds were previously processed by or on behalf of a designated entity. This is the most fundamental change to the compliance landscape of cryptocurrencies.

Indirect impressions are captured. The ban applies even if the sending and receiving account holders are not directly sanctioned. If the designated exchange appears anywhere in the payment chain as a transmitter, intermediary, or ultimate recipient, the transaction will be prohibited. If that logic extends to on-chain activity, UK VASPs would need to track the entire path of their funds beyond their direct counterparties.

Combined with Regulations 11 and 12 asset freezes, which also apply to today’s designations, which prohibit a British person from dealing with funds or economic resources owned, held or controlled by a designated person, and apply extraterritorially wherever the British person is located in the world, the practical effect is that UK VASPs are legally required to freeze funds linked to designated exchanges.

What this really means for UK VASPs and institutions

For UK VASPs and institutions, compliance standards have changed significantly. From today:

All funds held by a UK VASP or entity owned or controlled by a designated entity must be frozen. This is not an arbitrary judgment. This is a legal obligation resulting from an asset freeze. Wallet attributes and on-chain tracking become key to compliance. The Rule 17A prohibition captures any transaction in which a designated exchange appears in the payment chain, regardless of whether the funds were previously processed on or delivered to that exchange. Simply verifying the name of the direct counterparty is no longer sufficient. UK VASPs must track deposits coming through previous hops and assess the intended path of outbound transfers to identify designated exchange exposures. Suspicious activity must be reported to the National Crime Agency and OFSI notified where frozen funds are held in accordance with the reporting schedule or prohibited transactions are identified and prevented. The novelty of applying Regulation 17A to cryptocurrencies means compliance teams will need to pay close attention to regulators about how they operationalize the rules. OFSI guidance that specifically addresses the crypto-asset context is likely to follow. Package-oriented cryptocurrency exchange

Following Garantex’s outage, several cryptocurrency exchanges and cryptocurrency-adjacent institutions have been designated, reflecting the breadth of infrastructure that has stepped in to serve Russian users.

Huobi Global SA (HTX) is one of the world’s largest cryptocurrency exchanges, with a trading volume of $3.3 trillion in 2025. It is suspected of providing services to A7, an approved Russian payment network, and Garantex, an approved cryptocurrency exchange.

Rapira Group LLC is designated to participate in the Russian financial services sector.

Nueva Cryptologia SAS de CV (ABCEX) is a cryptocurrency trading platform linked to Sergei Mendeleev (also designated in today’s action), which UK authorities are citing as having suspected links to authorized exchanges Garantex and Grinex.

Aifory Pro is a Russian-based cash-to-cryptocurrency exchange designated for participation in the Russian financial services sector.

Arvix LLC is a cryptocurrency platform that has been flagged for suspicious links to approved exchanges Garantex and Grinex.

Bitpapa is a peer-to-peer cryptocurrency exchange based in the UAE that facilitates informal cryptocurrency trading between users. It was subject to U.S. sanctions in March 2024.

OJSC Crypto Asset Issuer (USDKG) is the issuer of the USDKG stablecoin, backed by the government of Kyrgyzstan, backed by gold and pegged 1:1 to the US dollar. He was designated for “carrying out business of economic importance to the Russian government.”

Alistera Limited has been appointed to support the A7 network.

Taken together, the exchange designation shows that the UK is targeting both large offshore venues with global user bases and smaller, locally embedded platforms handling ruble liquidity, cash-to-crypto conversions and stablecoin issuance.

A7 network exposed

A critical component of today’s package focuses on the entities behind A7, a Russian-linked network increasingly understood to play a central role in sanctions evasion, and A7A5, a ruble-backed stablecoin.

The UK designated all key individuals and entities: OJSC State Brokerage Company, Diamond Estate LLC, Trace Road LLC, Liran Cohen, Igor Gorin and Irina Akopyan.

Precedents shaping global cryptocurrency sanctions

The application of Regulation 17A to cryptocurrency exchanges marks a meaningful change in the way financial sanctions are translated into the digital asset space. Treating designated exchanges as functionally equivalent to designated banks for payment processing purposes is a long overdue adjustment and closes a gap that malicious actors have been exploiting for years.

Other jurisdictions will also be watching. Combining exchange-level designations with corresponding bank-style bans allows regulators to pursue offshore venues that have become the preferred infrastructure for evading Russian sanctions and provides a viable model for an increasingly wide range of illicit financial flows.

For companies operating in this space, the compliance implications are simple but challenging. If a Rule 17A style action applies, name screening will not cause any problems. What you really need is an operational capability to track transactions, not just at the time of onboarding, but across the entire chain, understand wallet activity, and identify exposure to a given entity.

How Elliptic Supports Our Customers

Elliptic has updated its dataset to reflect today’s designation. Customers using our product can view newly assigned exchanges, banks, and individuals, along with the properties of associated wallets and on-chain entities, reflected in their screening, monitoring, and investigation workflows.

Importantly, our transaction tracking capabilities allow UK VASPs and institutions to identify exposure to a given exchange across multiple hops. This is the type of indirect on-chain exposure that Regulation 17A currently includes within its scope. Our research team continues to track the A7 network and the broader ecosystem of Russian sanctions evasion, including the evolution of ruble-denominated stablecoin activity in the Eurasian region.

If you would like to discuss how today’s designation impacts your business or how Elliptic’s data and tools can support your compliance and investigative efforts in the new Regulation 17A environment, please contact our team.

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